Tax Alert: IRS Introduces New Form 15644 for Group Exemption Compliance
The IRS has announced that beginning in 2026, central organizations that maintain a group exemption must use Form 15644, “Supplemental Group Ruling Information,” to submit their annual supplemental group ruling information (SGRI) as required by section 7 of Rev. Proc. 2026-8. Form 15644 replaces the prior letter-style annual submission process and provides the IRS with a standardized reporting format. The new form is now the required method for satisfying the IRS’s annual reporting requirements for group exemptions, and for reporting changes to subordinate organizations.
In addition to the annual filing requirement, central organizations may submit Form 15644 throughout the year to report changes affecting subordinate organizations.
The purpose of Form 15644 is to:
- Update IRS records regarding subordinate organizations under a group exemption.
- Add or remove subordinate organizations from a group exemption.
- Terminate a group exemption.
- Report other changes required under Rev. Proc. 2026-8.
Generally, a central organization must submit Form 15644 annually to the IRS no earlier than 90 days, and no later than 30 days, before the end of the central organization’s annual accounting period. A central organization described in IRC Section 501(c)(3) that is a church or a convention or association of churches may, but is not required to, submit Form 15644. Additional Forms 15644 may be submitted at any time to report changes affecting subordinate organizations.
Form 15644 must be submitted by fax to (833) 312-5228. The IRS expects to replace the fax submission process with electronic filing in the future.
Rev. Proc. 2026-8 significantly modernized the IRS group exemption program and reinforces the annual reporting responsibilities of central organizations. Failure to timely update subordinate organization information may create compliance risks and could affect a group’s exempt status.
We recommend that central organizations review their current list of subordinates, verify all required information is current, and establish procedures to meet the new Form 15644 filing requirements.
If you have questions regarding group exemptions, Form 15644 reporting obligations, or the impact of Rev. Proc. 2026-8 on your organization, please contact GRF’s nonprofit tax team or use the contact button below.
